ML20054M573
| ML20054M573 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 04/27/1982 |
| From: | Madsen G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Pilant J NEBRASKA PUBLIC POWER DISTRICT |
| Shared Package | |
| ML20054M570 | List: |
| References | |
| NUDOCS 8207130623 | |
| Download: ML20054M573 (22) | |
Text
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f Docket:
50-298/81-26 g'lppnis Nebraska Public Power District
' ATTN:
Mr. J. M. Pilant, Division Manager Licensing and Quality Assurance P. O. Box 499 Columbus, Nebraska 68601 Gentlemen:
This refers to.the Systematic Assessment of Licensee Performance (SALP) Board Report of the Cooper Nuclear Station.
The SALP Board met on August 19, 1981, to evaluate the performance of the subject facility for the period July 1, 1980, through June 30, 1981.
The performance analyses and resulting evaluation are documented in the enclosed SALP Board Report.
These analyses and evaluation were discussed with you onsite on August 20, 1981.
The SALP Board evaluation process consists of categorizing performance in each functional area.
The categories which we have used to evaluate the performance of your facility are defined in Section II of the enclosed SALP Board Report.
As you are aware, the NRC has changed the policy for the conduct of the SALP program based on our experiences and the recently implemented reorganization which emphasizes the regionalization of the NRC staff.
This report is the product of the revised policy.
Any comments which you may have concerning our evaluation of the performance of your facility should be submitted to this office within 20 days of the date of this letter.
Your comments, if any, and the SALP Board Report, will both appear as enclosures to the Region IV Administrator's letter which issues the SALP Report as an NRC Report.
In addition to the issuance of the report, this letter will, if appropriate, state the NRC position on matters relating to the status of your safety program.
Comments which you may submit at your option, are not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, PL 96-511.
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Should you have any questions concerning this inspection, we will be pleased to discuss them with you.
Sincerely,
- original signed bys Q. L'. M ADSEN1 G. L. Madsen, Chief Reactor Project Branch 1 (SALP Board Chairman)
Enclosure:
Appendix - NRC Report 50-298/81-26 cc:
L. C. Lessor, Station Superintendent Cooper Nuclear Station P. O. Box 98 Brownville, NE 68321
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Appendix
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U. S. NUCLEAR REGULATORY COMI'SSION REGION IV System Assessment' of Licensee Perfor'mance ' '
Report:
50-298/81-26
. Docket:
50-298 Licensee:
Nebraska Public Power District P. O. Box 499 Columbus, NE 68601 Facility Name:
Cooper Nuclear Station Appraisal Period:
July 1, 1980-June 30, 1981 Appraisal Completion Date:
August 19, 1981 Licensee Meeting: August 20, 1981 SALP Board:
K. V. Seyfrit, Deputy Regional Administrator G. L. Madsen, Chief, Reactor Project Branch 1 B. L. Siegel, Licensing Project Manager, NRR T. F. Westerman, Chief, Reactor Project Section A D. L. DuBois, Resident Inspector Reviewed by:
//!fL T. F. Westerman, Chief Date'.
Reactor Project Section A Approved by:
h i w-
/[V [k G. L. Madsen, Chief Date Reactor Project Branch 1 SALP Board Chairman
O O
2 I.
Introduction
-tm NRC established a Systematic Assessment of Licensee Performance iSALP) program.
This SALP program is an-integrated NRC staff effort to collect available observations and data on a predetermined schedule and i
to evaluate licensee performance based on these observations and data.
Emphasis is placed upon NRC understanding the licensee's performance in the 14 functional areas listed in the body of the report and discussing and sharing this understanding with the licensee.
SALP is an integrated part of the regulatory process used to assure licensee's adherance to the NRC rules and regulations.
SALP is oriented toward furthering NRC's understanding of the manner in which:
(1) the licensee management directs, guides, and provides resources for assuring plant safety; and (2) such resources are used and applied.
The integrated SALP assessment is intended to be sufficiently diagnostic to provide meaningful guidance to licensee management related to quality and safety of plant operation, modifications and new construction.
The NRC SALP Board composed of NRC personnel who are knowledgeable of the licensee activities, met on August 19, 1981, to review the collection of data and observations to assess the licensee performance in the 14 selected functional areas.
This SALP report is the SALP Board's assessment of the licensee's safety performance at the Cooper Nuclear Station during the period of July 1, 1980, to June 30, 1981.
i The results of the SALP assessments in the selected functional areas were discussed with the following licensee's personnel at a meeting held on August 20, 1981.
Licensee Personnel C. R. Jones, Assistant General Manager-0perations D. E. Schaufelberger, Deputy General Manager R. S. Kamber, Senior Division Manager R. E. Buntain, Division Manager J. M. Pilant, Division Manager, Licensing & QA L. C. Lessor, Stat *on Superintendent II.
Criteria i
Licensee performance is assessed in 14 selected functional areas.
Each of these functional areas represents an area significant to nuclear safety and its related environment and is a programmatic area for the NRC inspection program.
Evaluation criteria as listed below was used, as appropriate, in each of the functional area assessments:
6
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V V
3 1.
Management involvement in assuring quality 2.
Approach to resolution of technical issues from safety standpoint 3.
Responsiveness to NRC initiatives 4.
Enforcement history 5.
Reporting and analysis of reportable events 6.
Staffing (including management) 7.
Training effectiveness and qualification In addition, SALP Board members considered other criteria, as appropriate.
Based upon the SALP Board assessment, each functional area evaluated is classified in one of the three performance categories.
The definition of these performance areas is:
Category 1:
A combination of attributes which demonstrates achievement of superior safety performance; i.e., licensee management attention and involvement are aggressive and oriented toward nuclear safety; licensee resources are ample and effectively used such that a high level of performance with respect to operational safety or construction is being achieved.
Reduced NRC attention may be appropriate.
Category 2:
A combination of attributes which demonstrates achievement of satisfactory safety performance; i.e., licensee management attention and involvement are evident and are concerned with nuclear safety; licensee resources are adequate and are reasonably effective such that satisfactory performance with respect to operational safety or construction is being achieved.
NRC attention should be maintained at normal levels.
Category 3:
A combination of attributes which demonstrates achievement of only minimally satisfactory safety performance; i.e., licensee management attention or involvement is acceptable and considers nuclear safety, but weaknesses are evident; licensee resources appear to be strained or not effectively used such that minimally satisfactory performance with respect to operational safety or construction is being achieved.
Both NRC and licensee attention should be increased.
III. Summary of Results In summary, the licensee's performance was classified as Category 1 in six areas, Category 2 in six areas, Category 3 in one area, and one area was not evaluated.
The licensee's performance was rated as Category 1 by NRR.
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IV Performance Analysis A.
Plant Operations 1.
Analysis There is a continuing audit by the resident inspector of plant operations.
There has been only one level V violation relating to improper tag-out of the RHR system.
The plant's excellent history of operation and orientation toward nuclear safety is reflective of the high degree of management attention demonstrated by the plant staff.
2.
Conclusions The licensee's performance in the area of " Plant Operations" was judged to fall into Category 1.
3.
Board Recommendations 1
This area may be considered for reduced NRC attention.
B.
Refueling Operations 1.
Analysis There were two unannounced inspections conducted during this inspection period.
Cooper has continued to demonstrate a well coordinated refueling operation.
2.
Conclusions The licensee's performance in the area of " Refueling Operations" was judged to fall into Category 1.
3.
Board Recommendations This area may be considered for reduced NRC inspection attention.
f C.
Maintenance 1.
Analysis Maintenance is inspected by both region-based inspectors and the resident inspector.
There was one level V violation relating to implementation of QA Program ANSI 18.7-1972 1
commi tments. There are some open items relating to documentation of testing, procedure guidance on use of vendor manual, and shop guides.
OO O
5 There were several LER's during the evaluation period which appear to be due to maintenance personnel error.
These include LER's 80-45 and 81-01 (Improperly Installed Hydraulic Snubbers), LER 81-07 (Temporary Air Pressure Gauge Resulted in Emergency Diesel Trip), LER 80-51 (Excessive Teflon Material HPCI Valve), and LER 81-17 (RCIC Jumper Not Installed).
2.
Conclusions The licensee's performance in the area of " Maintenance" is considered to be Category 2.
3.
Board Recommendations NRC attention should be maintained at the normal level.
D.
Surveillance and Inservice Testing 1.
Analysis During the inspection of this area by both region-based inspectors and the resident inspector, there have been no violations or deviations identified.
The two HPCI'isolations which occurred following surveillance testing (LER's 79-41 and 80-32) were identified as possibly casually-linked.
The licensee indicated his intent to look further into these two LER's.
2.
Conclusions The licensee's performance in the area of " Surveillance and Inservice Testing" is considered to be Category 1.
The licensee has a well established system for implementing their surveillance and inservice testing program.
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3.
Recommendations This area may'be considered'for reduced NRC inspection attention.
E.
Personnel, Training, and Plant Procedures 1.
Analysis There~have been two inspections of training during this evaluation period.
One infraction was identified relating to initiation of requalification lecture series and grading of requalification quiz to determine weak areas.
A deviation was l
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J also identified relative to coverage of the Station QA Program in the annual examination.
There are several unresolved items relative to documentation of training.
Region IV has expressed a specific concern to IE:HQ relative to the long-term training program associated with the shift supervisor assuming the STA role.
Training in the area of emergency preparedness during the Emergency Preparedness Appraisal Team audit in June 1981 was not found to be complete in development.
There has been one inspection in the areas of personnel and procedures by region-based inspectors.
No violations or deviations were identified.
I 2.
Conclusions The licensee's performance in the area of " Personnel" is considered to be Category 1.
The licensee's performance in the area of " Training and Procedures" is considered to be-Category 2.
The licensee's overall performance in this func-tional area is considered to be Category 2.
3.
Recommendations NRC attention should be maintained at the normal levels.
F.
Fire' Protection and Housekeeping 1.
Analysis There has been one inspection of this area conducted by a regional inspector. Two infractions were identified relative l
to breached fire barrier and an open fire door.
I 2.
Conclusions The licensee's performance in the area of " Fire Protection and Housekeeping" is considered to be Category 2.
3.
Board Recommendations NRC attention should be maintained at the normal level.
G.
Design Changes and Modifications 1.
Analysis There has been one inspection by a region-based inspector.
No violations or deviations were identified.
There is an unresolved item relative to procedure revision concurrent with design changes.
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7 2.
Conclusions The licensee's performance in the area of " Design Changes and Modifications" is considered to be Category 1.
3.
Recommendations This area may be considered for reduced NRC inspection dttention.
H.
Radiation Protection, Radioactive Waste Management, and Transportation 1.
Analysis One inspection was performed during the evaluation period by the Technical Program Branch.
This inspection covered the licensee's Radiation Protection Program during refueling activities and a follow up of open items identified in the Health Physics Appraisal. conducted during May 1980.
No violations, deviations oriunresolved items were identified in the above inspection.
One violation was identified by the State of Nevada regarding a damaged radioactive waste container received on January 19, 1981, at the Beatty, Nevada, burial site.
This violation involved:
Severity level III violation for a failure to meet applicable Department of Transportation requirements.
A proposed Notice of Civil Penalty was not issued because i
the actual threat to the health and safety of the public, i
and the licensee's immediate corrective action was such
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that a civil penalty was not warranted.
The licensee has made good progress on closing out the significant findings in the Health Physics Appraisal.
Only one item remains open.
A confirmatory measurements insoection was conducted during June 15-19, 1981.
The results from all the analytical l-measurements have not been completed.
An initial review of the analytical data indicates that the licensee's results are j
acceptable.
l 2.
Conclusions l
The licensee's performance in the area of " Radiation Protection, Radioactive Waste Mananement, and Transportation" is considered to be Category 2.
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<8 3.
Board Recommendations NRC attention should be maintained at the normal level.
I.
Environmental Protection 1.
Analysis There have been no inspections of this area during this evaluation period.
2.
Conclusions Not evaluated.
3.
Board Recommendations None.
J.
Analysis One inspection was conducted by the Technical Program Branch prior to the implementation of the post-TMI Emergency Preparedness requirements.
There were no significant findings from this inspection.
An Emergency Preparedness Appraisal Team audit was conducted during the period of June 15-16, 1981.
The program was found to contain significant weaknesses based on post-TMI Emergency Preparedness requirements.
The appraisal findings indicate that the major causes of these deficiencies were ineffective administration and management of l
the overall development and implementation of the emergency l
preparedness program and a very limited scope of training of I
the station personnel.
Emergency Plan and procedure incongruities, conflicts and-omissions in particular, gave the appearance that there had been a lack of continuity and coordination between the licensee's corporate and site emergency planning staffs during the development process.
l These observations were substantiated during discussions with l
the site and corporate planning and management staffs.
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9 The licensee's emergency organization description was incomplete in that it did not adequately define the authorities, responsibilities and interrelationships for performing the various emergency tasks and functions described in the Emergency Plan. Within the scope of procedures developed to implement the Emergency Plan, there were conflicting and unclear delineations of key duties and responsibilities relatad to overall coordination of the emergency response and the development of protective action recommendations.
The licensee's emergency action levels (EALs) were not understandable to the primary users who would be responsible for detecting emergency conditions and initiating appropriate emergency actions.
The training program was not completely developed but individuals had received some limited training, within the last few weeks before the NRC Appraisal; however, the training was limited to discussions of the four classes of emergencies and the emergency action levels (EALs) which fall within each class.
Observation and questioning of selected individuals during the walk-throughs of their assigned emergency tasks and functions indicated that the individuals were aware of many of the organizational and procedural shortcomings but could perform effectively in spite of them for emergencies which did not result in gross damage to the plant or require significant offsite responses.
Licensee coordination with various non-licensee agencies, other than with the NRC, was not considered adequate.
NRC Appraisal Team auditors concluded that the licensee appeared to be capable of responding to and managing the response to events of limited scope and duration.
The ability to respond and manage the response to broader scope of events of longer duration, however, was suspect and the team concluded that there was not reasonable assurance that such a response could be effectively implemented given the present state of development of the emergency preparedness program.
2.
Conclusions The licensee's performance in the area of " Emergency Preparedness is considered to be Category 3.
A management meeting is being planned to discuss licensee actions to correct the deficiencies in the Emergency Preparedness Program.
The licensee has contracted a consultant to assist in upgrading their program.
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10 3.
Board Recommendations Increased attention by licensee management and the NRC is recommended.
K.
Security and Safeguards 1.
Analysis Three unannounced physical security inspections were performed during the evaluation period and no violations were reported by the inspectors.
Some minor problems were discovered during these inspections and were corrected by Cooper Nuclear personnel prior to the inspectors leaving the site, except for one item of concern during September 1980.
The licensee committed to providing tamper switches or triggering mechanisms electrically compatible with their intrusion system and did so prior to the next inspection in December 1980.
An Immediate Action Letter, dated October 9, 1980, was sent to Nebraska Public Power District requesting a change in their security plan audit frequency in accordance with 10 CFR 50.54(p). The audit frequency change was verified during the inspection in December 1980.
One item of concern to the regional inspectors, however, is that a new Administrative Supervisor has been named at Cooper and has no previous security experience.
2.
Conclusions The licensee's performance in the area of " Security and Safeguards" is considered to be Category 2.
f 3.
Board Recomme dations NRC attenti'on should be mai.ntained at the normal level.
L.
Audits, Reviews and Committee Activity 1.
Analysis,
One inspection in this area has'been conducted by region-based inspectors.
No' violations or deviations were identified.
2.
Conclusions The licensee's performance in the area of audits, reviews and committeee activity is considered to be Category 1.
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3.
Board Recommendations 4
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Thisareamaybeconsideredf5rreduced'NRCl. inspection attention.
M.
Administration, QA Records, and' Procurement 1.
Analysis Inspections were conducted inLthe areas of administration and procurement by region-based inspectors during this evaluation period. One Level V violation was identified relative to documentation.
2.
Conclusions The licensee's performance in the area of " Administration,_QA Records and Procurement" is considered to be Category 2.
3.
Board Recommendations NRC attention should be maintained at the normal level.
N.
Corrective Action and Reporting 1.
Analysis There is a continuing inspection of this area by the resident inspector.
No violations or deviations were identified.
The licensee reporting is normally complete and corrective actions are responsive to generic issues.
One area commented on by the Board was that the licensee.does, in. general, identify repeated events; however, there appear to be some cases in which this has not been accomplished.
2.
Conclusions t
The licensee's performance in the area of " Corrective Action and Reporting" is considered to be Category 1.
3.
Board Recommendations This area maybe considered for reduced NRC inspection.
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VJ SupportingDataandSuhries 12 A.
Noncompliance Data Investigation
& Inspection Noncompliances and Deviations Functional Area Manhours Severity Level Classification
- Dev 1
11 III IV V
IV Vio.
Inf.
Def.
- 1. Plant Operations 398 1
- 2. Refueling Operations 59
- 3. Maintenance '
78 1
- 4. Surveillance &
Inservice Testing 118 IDe-
- 5. Personnel, Train-54 1
v Stion ing & Plant Procedures
- 6. Fire Protection 4
2
& Housekeeping
- 7. Design Changes &
Modifications 31
- 8. Radiation Protection, Radioactive Waste Management & Trans-portation 60 1
- 9. Environmental Protection 0
- 10. Emergency Prepared-ness 711
- 11. Security &
Safeguards 157
- 12. Audits, Reviews &
Committee Activity 34
- 13. Administration, QA Records, Procurement 31
- 14. Corrective Actions
& Reporting 153 1
TOTALS 1888*
- There are an additional 360 hours0.00417 days <br />0.1 hours <br />5.952381e-4 weeks <br />1.3698e-4 months <br /> spent in other activities such as TMI Follow up, Independent Inspection, and Management Entracne & Exit Meetings.
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13 B.
Licensee Event Reports (LER) l The Regional SALP Board reviewed tha LER's for the period of July 1, 1980, through June 30, 1981. This includes LER's 50-298/80-16, 19, ;20, 23, 24, 25, 26, 28, through 81-18.
The previous evaluation period for 1979 1980 was reviewed for causally-linked LER's.
The classification and number of LER's during this report period are as follows:
Number Component Failure 19 Design / Fabrication 5
Personnel Error 8
Defective Procedures 4
Other 14 Causally-Linked 10
^
There were three generic areas identified during the review of the LERs.
In each area there has been action initiated as follows:
. Reactor Equipment Cooling System (LERs 79-29, 79-43, 80-05, and 80-09):, In addition to lice'nsee repairs, GE is reviewing the weld leaks and a report is to be issued by GE.
Emergency Diesels (LERs 79-33, 79-34, 79-36, 79-37, 80-27, 81-04, and 81-07).
A. purchase order has been issued to Cooper Nuclear Services to review the diesel problems and initiate corrective action during the turbine outage planned for September 1981.
HPCI System (LERs 79-25, 80-02, 80-35, 80-51, and 81-14):
In addition to the corrective action taken by the licensee, NPPD is supporting the GE Task Group as well as the INP0 generic review of HPCI system problems.
There were ten causally-linked items identified during this review period as follows:
Penetration Leakage - LERs 80-12 and 81-15 Limitorque Valve Key Failure - LERs 80-30 and 80-47 HPCI Isolation following Surveillance - LERs 79-41 and 80-32
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14 RHR Pump 1D Breaker Failure - LERs 79-42 and 80-34 RHR Valves SW-MD-89^. and 89A Cavitation / Vibration related problems - LERs 80-37 and 80-42 (In addition, LERs 80-43 and 80-52 also involved this valve.)
Barton 288 Differential Pressure Switch Malfucntions - LERs 79-23, 79-27, and 80-38 Rad Waste Valve RW-A0-94 Failure Open/Close Position - LER 80-36 and 80-46 MSIV 86A Closing Time - LERs 80-21 and 80-49 Improper Installed Hydraulic Snubbers - LERs 80-45 and 81-01 Barksdale Pressure Switch Model B2T Malfunction - LERs 70-24, 80-17, 81-12, 81-18 The licensee is responsive in each of these areas.
C.
Escalated Enforcement Actions Civil Penalities None Orders None Immediate Action Letters October 9, 1980, letter relating to security audit frequency.
D.
Management Conferences Held During Past Twelve Months None E.
NRR Performance Evaluation 1.
Facility Data Facility:
Nebraska Public Power District (NPPD)
Cooper Nuclear Station (CNS)
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Project Manager:
Byron Siegel Branch Chief, CRB#2:
Thomas A. Ippolito Appraisal Period: July 1, 1980, to June 30, 1981 a.
Performance Elements (1) Quality of Responses and Submittals NPPD has submitted numerous TS changes, generic letter responses, and responses to requests for additional information during this appraisal period.
The overall quality of these responses and submittals has been good and often provide more than just the minimally requested or needed to be acceptable.
Complete documentation with regard to references to previous submittals and correspondence, and licensing actions has-consistently been provided with all correspondence.
(2) Effort Required to Obtain an Acceptable Response Timeliness:
Meet required date most of the time and provide notification when schedule will not be met.
Effort:
Little effort has been required to obtain an acceptable response.
Responsiveness to Staff Requests:
Good, seldom requires follow-up action to obtain information.
Anticipates or Reacts to NRC needs:
Yes, in several instances that I am personally aware of l
they have reacted to NRC needs without being proded (i.e., interaction between offsite power i
and Mark I containment program).
l (3) Working Knowledge of Regulations, G,uides, Standsrds, and Generic Issues Good.
Knowledge'in all these areas and their affect on CNS and NPPD.
(4) Technical Competence l
l Good.
CNS has a small technical staff relative to most other utilities.
This is supplemented with o
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16 contracted technical services when needed.
This combination has adequately provided the needed technical expertise to operate the plant and respond to the staff's requests and requirements.
(5) Conduct of Meetings with NRR Since I have not attended a meeting with NPPD or CNS in the nine months I have been Project Manager, I cannot comment.
(6) Long Standing Open Items Other than the action plan items, CNS has approximately 29 long standing open items.
Most of these are generic or multiplant action items which are in various stages of staff resolution.
Cooper has been responsive to staff requests on these items.
(7) Organization and Management Capabilities I have not had sufficient interaction at this time to evaluate this performance aspect.
(8) Results of Operator Licensing Examinations Conducted During Appraisal Period Examinatiuns for eight applicants were completed between July 1, 1980,'and June 30, 1981; seven passed and one failed.
(9) Performance on Specific Issues j
As lead PM on the' implementation of the Mark I Containment ?rogram, I am familiar with the overall effort and the CNS effort relative to other licensees.
CNS has been very responsive in complying
.with the requirements of NUREG-0661 and the Commission's Order date of September 1982.
Their effort"in this program is evident by the fact l
that they are one of the few utilities that expect-to meet the Order date without requiring I
an additional time extension.
This has been i
achieved by proceeding with design changes prior l
to completion of the analyses and b/ utilization of contractors to perform the design and analyses independent of other licensees who have entered into group agreements.
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17 i
b.
Observed Trends in Performance There have been no significant changes in the NPPD licensing staff or in the plant management during the 9 months I have been PM and I have not noticed any changes in performance during this time.
c.
Notable Strengths and Weaknesses (1) Strengths NPPD CNS is cooperative and responsive to the staff's requests for information and in complying with the staff's requirements. They appear to have a good system for documentation of correspondence and of keeping track of dates, responses, and submittals are due.
(2) gaknesses NPPD/CNS being a small utility located in a fairly isolated region of the country has limited sources and difficulty in attracting professional personnel with the background and experience desired.
They have been able to compensate for this by contracting l
work; however, there are limitations to the type of work that can be done on contract.
If Cooper should loose some of their professional staff as a result of i
the current competitiveness within the industry, they could be left in a potentially serious position.
An example of their relatively unique situation is j
related to the resolution of the STA requirement brought about by TMI.
CNS has combined the STA function with the shift supervisor duties and added a second SR0 to each shift.
This has been brought l
about because degreed engineers working at CNS did l
not want to work shift and they have not been l
successful in attracting engineers from cutside to perform the STA function.
An existing weakness has been identified and related to plant training.
The following information provided the basis for this conclusion:
A June 25, 1981, memo to NRR from IE identified their concern related to the quality of current training and the absence
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18 1
l of a long-range training program associated with the shift supervisor assuming the STA function; In the draft emergency preparedness (EP) 4 appraisal report based on the June 1981 EP review, training was identified as a specific weakness; and j
IE Inspection Report 50-298/81-05, which addressed the licensee's conduct of i
non-licensed training and records thereof, identified specific weaknesses.
The draft Emergency Preparedness appraisal report also stated that the ability of the i
licensee to handle emergencies of a broad scope and duration was. suspect since a response could not be effectively implemented given the present state of their emergency preparedness program.
2.
Overall Summary Based on my interactions with the licensee, I would rate their performance as Category 1.
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